• Insights

The Impact of Comprehensive Sickness Insurance on EEA Permanent Residency

March 28, 2017

Countries / Territories

  • 🌐

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

According to a recent Liberal Democrats analysis reported in The Guardian, in the last two quarters of 2016, more than 12,800 EU citizens had their permanent residency requests refused with a further 5,500 declared invalid, a rejection rate of around 28%.

To qualify for permanent residency in the UK, EEA nationals need five years of continued residence in the UK and must meet certain criteria. We are aware of a recent trend in residency applications submitted by EEA citizens relying on the period of time spent as students or as self-sufficient persons being refused on the grounds that they did not hold Comprehensive Sickness Insurance (CSI) coverage. These cases highlight a little-known requirement, which has the capacity to seriously prejudice an application for permanent residency.

When do EEA Nationals Require Comprehensive Sickness Insurance?

Under EU law, EEA citizens who are students, or self-sufficient persons resident in another member state for more than 3 months must have their own medical insurance. The CSI rule was designed as a barrier against benefit tourism.

This covers applications for Residence Cards and Permanent Residence cards, and also applies to non-EEA family members applying on the basis that their EEA national family member is exercising Treaty rights and sponsoring them in the UK.

Applicants must submit evidence that they:

  1. Have sufficient resources for themselves and family members so as not to become a burden on the social assistance system of the host Member State and have comprehensive sickness insurance cover in the host Member State; or
  2. Are enrolled as students within the host Member State and have Comprehensive Sickness Insurance cover and assure the national authorities that they have sufficient resources for themselves and family members not to become a burden on the social assistance system of the host Member State during their period of residence; or
  3. Are family members of Union citizens falling within one of the above categories.

Applications will normally be refused if none of these conditions are met.

What Documents can an EEA National or their Family Members Provide to Show they have CSI?

EEA nationals applying for documentation confirming their right to reside in the UK as a student or self-sufficient person must present one of the following forms of evidence covering the duration of period of residence in the UK.

For applications for a registration certificate or a residence card, they must provide one of the following documents to show they have CSI: 

  1. A comprehensive insurance policy document confirming that the applicant has private medical insurance. When considering what is ‘comprehensive, the caseworker may accept for example, a policy containing certain exemptions if the applicant is  covered by  the  policy  for medical treatment in the majority of circumstances; or
  2. For persons temporarily in the UK, a valid European Health Insurance Card (EHIC). The EHIC is the replacement for form E111. It must have been issued by a member state other than the UK because the member state that issued the card will cover the cost of treatment. The applicant must also provide a statement of intent that they intend to return to their home country; or  
  3. In certain circumstances, Form S1, S2 or S3. The S1 form is a certificate of entitlement to health care in another EEA country for a limited duration and may only be used in limited circumstances; for example, by state pensioners or dependents of an insured person working in another Member State. The S2 form covers the actual cost of treatment; for example, for insured persons who are referred for specific treatment in another EEA country or Switzerland. The S3 form will cover the cost of treatment; for example, for retired frontier workers continuing treatment in the Member State they previously worked.

For applications for a document certifying permanent residence or a permanent residence card, they must provide one of the following documents or a combination of these documents covering the whole of their 5 years continuous residence in the UK:  

  1. A comprehensive private medical insurance policy document; or 
  2. A valid European Health Insurance Card (EHIC) issued by an EEA member state other than the UK (or its predecessor form E111); or 
  3. Form S1 (or its predecessor forms E109 or E121), Form S2 (or its predecessor form E112) or Form S3. 

If the applicant submits an EHIC which does not cover the whole of the period relied upon, or does not feature a valid from date, they must also submit evidence from the issuing authority confirming that they held a valid EHIC card for the period relied upon. 

If the applicant submits Forms S1, S2 or S3 they must provide one or a combination of these forms for their 5 years continuous residence. It is possible to apply to the country of origin retrospectively for these certificates.

What Happens If You have not had CSI and Your Application is Refused?

A refusal means that Permanent Residence will not be granted, but this does not mean removal from the UK.

There were growing fears among EEA citizens that they would be deported for not complying with the requirement to have CSI after a German student was warned by a UKVI official that she could be removed if she could not show insurance documents.  

On 1st March 2017, the Home Office confirmed that this will not be acted upon, and issued the following statement:

“EU citizens will not be removed from the UK or refused entry solely because they do not have comprehensive sickness insurance.”

Countries / Territories

  • 🌐

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Article

EU Inc. Signals a Shift: Why Immigration Will Matter to Europe’s New Corporate Agenda 

Knowledge Management Director Ana Sofia Walsh and Senior Client Engagement Manager Soraya Driessen examine the European Commission’s EU Inc. proposal and its potential to reshape corporate structures across the EU, highlighting the resulting complexities and unresolved questions for immigration, work authorization and cross-border workforce mobility.

Learn more

Media mentions

The National: Companionship Scheme Addresses Loneliness Among Elderly as UAE Population Ages

Partner Ali Haider discussed how flexible residency pathways, strong infrastructure and access to healthcare are continuing to drive interest among retirees looking to relocate to the UAE.

Learn more

Fragomen on immigration

Business Immigration After the Midterms (Part 1): What to Expect No Matter What

Partner K. Edward Raleigh analyzes how post‑midterm US business immigration will shift toward heightened enforcement, worker‑protection scrutiny and cross‑agency oversight, urging employers to align hiring practices, sponsorship decisions and documentation with consistent, defensible workforce strategies.

Learn more

Media mentions

Business Insider: Trump’s Green Card Memo Dropped Before a Holiday Weekend. Immigration Lawyers Say Clients Panicked.

Counsel Brian Hunt said employers quickly sought clarity after a USCIS memo on green card adjustment of status raised questions about immigration timelines, work continuity and travel planning.

Learn more

Awards

Fragomen named “Law Firm of the Year” for Immigration Law by Best Law Firms™ - Australia

Fragomen is named “Law Firm of the Year” for Immigration Law by Best Law Firms™ - Australia and receives National and Regional Tier 1 rankings in Immigration Law.

Learn more

Media mentions

USA Today: USCIS Green Card Announcement Spurs Confusion. What to Know

Partner Parisa Karaahmet discusses the broad application of a USCIS memo to adjustment of status applicants and notes that H- and L-visa holders may have a somewhat easier burden in demonstrating factors that support favorable discretion.

Learn more

Article

Commonwealth Games 2026 Travel Planning: UK ETA Rules for Teams and Fans

Senior Manager Alice Spaull and Associate Stephanie Fitton examine the evolving UK immigration and Electronic Travel Authorisation (ETA) requirements for athletes, their support teams and associated guests attending the Commonwealth Games 2026, highlighting key compliance risks and the importance of early travel planning.

Learn more

Media mentions

The Associated Press: Trump’s Latest Immigration Move Clouds the Path to Green Cards

Partner Kevin Miner discusses the expected impact of new USCIS green card guidance on employment-based immigration, noting dual-intent visa cases would likely continue under business as usual with no significant impact.

Learn more

Media mentions

The Wall Street Journal: What to Know About the Trump Administration’s New Green Card Policy

Partner K. Edward Raleigh discusses a recent USCIS memo that appears to signal greater caution in how adjudicators assess adjustment of status cases rather than establishing a new legal standard.

Learn more

Fragomen news

2026年5月 アメリカ移民法ダイジェストLearn more

Video

Germany Health Insurance Requirements for Visas: What You Need to Know

Senior Manager Sumejja Handzo outlines Germany’s health insurance requirements for visas and residence permits, including coverage options, documentation considerations and key compliance requirements for foreign nationals relocating to Germany.

Learn more

Media mentions

ABA Journal: Will US Immigration Policies Create ‘Chilling Effect’ on World Cup?

Partner Daniel Schwarz highlights how US visa appointment backlogs and limited availability for B visas are shaping international travel planning for the upcoming World Cup.

Learn more

Article

EU Inc. Signals a Shift: Why Immigration Will Matter to Europe’s New Corporate Agenda 

Knowledge Management Director Ana Sofia Walsh and Senior Client Engagement Manager Soraya Driessen examine the European Commission’s EU Inc. proposal and its potential to reshape corporate structures across the EU, highlighting the resulting complexities and unresolved questions for immigration, work authorization and cross-border workforce mobility.

Learn more

Media mentions

The National: Companionship Scheme Addresses Loneliness Among Elderly as UAE Population Ages

Partner Ali Haider discussed how flexible residency pathways, strong infrastructure and access to healthcare are continuing to drive interest among retirees looking to relocate to the UAE.

Learn more

Fragomen on immigration

Business Immigration After the Midterms (Part 1): What to Expect No Matter What

Partner K. Edward Raleigh analyzes how post‑midterm US business immigration will shift toward heightened enforcement, worker‑protection scrutiny and cross‑agency oversight, urging employers to align hiring practices, sponsorship decisions and documentation with consistent, defensible workforce strategies.

Learn more

Media mentions

Business Insider: Trump’s Green Card Memo Dropped Before a Holiday Weekend. Immigration Lawyers Say Clients Panicked.

Counsel Brian Hunt said employers quickly sought clarity after a USCIS memo on green card adjustment of status raised questions about immigration timelines, work continuity and travel planning.

Learn more

Awards

Fragomen named “Law Firm of the Year” for Immigration Law by Best Law Firms™ - Australia

Fragomen is named “Law Firm of the Year” for Immigration Law by Best Law Firms™ - Australia and receives National and Regional Tier 1 rankings in Immigration Law.

Learn more

Media mentions

USA Today: USCIS Green Card Announcement Spurs Confusion. What to Know

Partner Parisa Karaahmet discusses the broad application of a USCIS memo to adjustment of status applicants and notes that H- and L-visa holders may have a somewhat easier burden in demonstrating factors that support favorable discretion.

Learn more

Article

Commonwealth Games 2026 Travel Planning: UK ETA Rules for Teams and Fans

Senior Manager Alice Spaull and Associate Stephanie Fitton examine the evolving UK immigration and Electronic Travel Authorisation (ETA) requirements for athletes, their support teams and associated guests attending the Commonwealth Games 2026, highlighting key compliance risks and the importance of early travel planning.

Learn more

Media mentions

The Associated Press: Trump’s Latest Immigration Move Clouds the Path to Green Cards

Partner Kevin Miner discusses the expected impact of new USCIS green card guidance on employment-based immigration, noting dual-intent visa cases would likely continue under business as usual with no significant impact.

Learn more

Media mentions

The Wall Street Journal: What to Know About the Trump Administration’s New Green Card Policy

Partner K. Edward Raleigh discusses a recent USCIS memo that appears to signal greater caution in how adjudicators assess adjustment of status cases rather than establishing a new legal standard.

Learn more

Fragomen news

2026年5月 アメリカ移民法ダイジェストLearn more

Video

Germany Health Insurance Requirements for Visas: What You Need to Know

Senior Manager Sumejja Handzo outlines Germany’s health insurance requirements for visas and residence permits, including coverage options, documentation considerations and key compliance requirements for foreign nationals relocating to Germany.

Learn more

Media mentions

ABA Journal: Will US Immigration Policies Create ‘Chilling Effect’ on World Cup?

Partner Daniel Schwarz highlights how US visa appointment backlogs and limited availability for B visas are shaping international travel planning for the upcoming World Cup.

Learn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsVietnamese ImmigrationView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • Vietnamese Immigration
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
May 28, 2026 | United StatesBusiness Insider: Trump’s Green Card Memo Dropped Before a Holiday Weekend. Immigration Lawyers Say Clients Panicked.
May 29, 2026 | BermudaBermuda: New Work Permit Policy to Prolong Processing Times
May 29, 2026 | FranceFrance: EU Blue Card Rules Relaxed
May 29, 2026 | IrelandIreland: Occupation Lists Changes Published,“50:50” Rule Modification Proposed
May 29, 2026 | United Arab EmiratesThe National: Companionship Scheme Addresses Loneliness Among Elderly as UAE Population Ages
May 28, 2026 | United StatesBusiness Insider: Trump’s Green Card Memo Dropped Before a Holiday Weekend. Immigration Lawyers Say Clients Panicked.
May 29, 2026 | BermudaBermuda: New Work Permit Policy to Prolong Processing Times
May 29, 2026 | FranceFrance: EU Blue Card Rules Relaxed
May 29, 2026 | IrelandIreland: Occupation Lists Changes Published,“50:50” Rule Modification Proposed
May 29, 2026 | United Arab EmiratesThe National: Companionship Scheme Addresses Loneliness Among Elderly as UAE Population Ages
May 28, 2026 | United StatesBusiness Insider: Trump’s Green Card Memo Dropped Before a Holiday Weekend. Immigration Lawyers Say Clients Panicked.
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.